Privacy Policy

1. Who We Are

Data Controller: Bach Trinh (QBTEcu — VAG Remote Coding Service)

Trading name: Bach Trinh

Registered address: Fibichova 669, 738 01 Frýdek-Místek – Místek, Czech Republic

IČO (Company ID): 19733950

DIČ (VAT ID): CZ0003025374

Register: RES (Registr ekonomických subjektů)

Contact: +420 773 585 568 (WhatsApp)

Instagram: @vagremotebyqbtecu

We are a registered sole trader operating EU-wide, offering professional remote ECU coding services for VAG Group vehicles (Volkswagen, Audi, Škoda, SEAT, Lamborghini, Bentley) via official ODIS software.

2. What Personal Data We Collect

When you book a service or contact us, we may collect the following personal data:

• Identity data: First name, last name
• Contact data: Email address, phone number / WhatsApp
• Billing data: Street address, city, postcode, country
• Vehicle data: VIN number, vehicle brand, model and year
• Identity verification documents: Copy of ID card, passport or driving licence; vehicle registration document; photo of licence plate; photo of VIN
• Communication data: Messages exchanged via WhatsApp or other channels
• Technical data: IP address, browser type (collected automatically when visiting our website)

3. Why We Collect Your Data (Legal Basis)

We process your personal data on the following legal bases under GDPR Article 6:

• Contract performance (Art. 6(1)(b)): Name, contact details, VIN and vehicle data are necessary to provide the remote coding service you have requested.
• Legal obligation (Art. 6(1)(c)): Identity verification documents (ID, vehicle registration, VIN photo, licence plate photo) are collected and retained as required by our contractual agreement with Volkswagen Group. This obligation requires us to verify vehicle ownership before performing any online ODIS operation and to retain these records for 15 years.
• Legitimate interest (Art. 6(1)(f)): Basic technical data (IP address, browser) for website security and fraud prevention.
• Consent (Art. 6(1)(a)): Where you have explicitly consented via our booking form.

4. How Long We Keep Your Data

• Identity verification documents (ID, passport, driving licence, vehicle registration, VIN and plate photos): 15 years — as required by our VW Group service agreement.
• Billing and transaction data: 10 years — as required by applicable tax and accounting laws.
• Contact and communication data: Up to 3 years after last contact, or until you request deletion.
• Website technical data: Up to 12 months.

5. How We Store and Protect Your Data

Your personal data and documents are stored securely using encrypted storage. We apply appropriate technical and organisational measures to protect your data against unauthorised access, loss or disclosure, in line with GDPR Article 25 (data protection by design and by default).

• Documents are stored in encrypted form
• Access is restricted to us only — no third-party staff have access
• We do not use shared or cloud platforms that allow third-party access to your documents

6. Who We Share Your Data With

We do not sell, rent or share your personal data with third parties for marketing or commercial purposes.

Your data may be shared only in the following limited circumstances:

• VW Group online systems: Your VIN is transmitted to Volkswagen Group servers during the ODIS online coding session. This is technically required to perform the service. VW Group acts as an independent data controller for this data.
• Payment processors: Revolut or PayPal — when you make payment. These services have their own privacy policies and GDPR compliance obligations.
• Legal obligation: If required by law, court order or competent authority.

7. Your Rights Under GDPR

As an EU resident, you have the following rights regarding your personal data:

• Right of access (Art. 15): You can request a copy of all personal data we hold about you.
• Right to rectification (Art. 16): You can ask us to correct inaccurate or incomplete data.
• Right to erasure (Art. 17): You can request deletion of your data, subject to our legal retention obligations. Note: identity verification documents cannot be deleted before the 15-year retention period expires due to our VW Group contractual obligation.
• Right to restriction (Art. 18): You can request that we restrict processing of your data in certain circumstances.
• Right to data portability (Art. 20): You can request your data in a structured, machine-readable format.
• Right to object (Art. 21): You can object to processing based on legitimate interests.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing before withdrawal.

To exercise any of these rights, contact us via WhatsApp at +420 773 585 568. We will respond within 30 days.

8. Data Transfers Outside the EU

We do not intentionally transfer your personal data outside the European Economic Area (EEA). However, please note that WhatsApp (Meta Platforms) and PayPal may process data on servers outside the EU — these services operate under their own GDPR-compliant data transfer mechanisms (Standard Contractual Clauses or adequacy decisions).

9. Cookies

Our website does not use tracking cookies, advertising cookies or analytics tools that collect personal data. We do not use Google Analytics or similar services. Basic session functionality may use essential cookies only, which do not require consent under GDPR.

10. Right to Complain

If you believe we have not handled your personal data correctly, you have the right to lodge a complaint with your national data protection supervisory authority. In the Czech Republic this is:

Úřad pro ochranu osobních údajů (UOOU)
Pplk. Sochora 27, 170 00 Prague 7
www.uoou.cz

11. Changes to This Policy

We may update this Privacy Policy from time to time. The current version will always be available on this page with the date of last update. We encourage you to review this page periodically.

Questions? Contact us via WhatsApp or Instagram.
Bach Trinh · IČO: 19733950 · DIČ: CZ0003025374 · Fibichova 669, 738 01 Frýdek-Místek